GameLoop Privacy Policy

Welcome to GameLoop!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with GameLoop (the “App”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

By installing, logging-in, or using the App, you are acknowledging our rules regarding the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the App.

This App has been developed by Oriental Power Holdings Limited (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the App is Oriental Power Holdings Limited, with registered address at 29/F, Three Pacific Place, No. 1 Queen’s Road East, Wanchai, Hong Kong. Our data protection officer can be contacted at privacy@gameloop.com.

Our representatives for data protection purposes in certain jurisdictions are as follows:

Jurisdiction

Representative

Address

Contact details

Tencent International Service Europe B.V.

Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands

eudataprotection@tencent.com

South Korea

Tencent Korea Yuhan Hoesa

152 Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea

+86 0755 8376 5566

privacy@gameloop.com

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at privacy@gameloop.com.

The Ty pes of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high-level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party).

GameLoop App Log-in information: When you choose to log-in to the App via your Facebook account or your Google account: information we may import from your connected social media account including your name as it appears on your social media profile, your email, your user ID and your profile picture(s) (if any)), your location, and language settings in order to set up your profile and provide you access to the App.

Game Log-in information: When you access or log-in to the specific game(s) via the GameLoop App: your name, username, email address, contact number and information you submit through your chosen method of log-in for the relevant game (including via guest log-in (if available and where applicable), or through your Facebook account, Google account, Twitter account, Apple iOS Game Center, Nintendo account, Pokemon Trainer Club account, Garena account, Activision account, VK account, where applicable), your user ID, your user profile, and your profile picture(s) (if any)).

Survey information: If you choose to participate in a survey about the Service, you may be asked to provide certain personal information, such as your email, social media ID, geographic (country) location, game information (game habits and preferences, e.g. recently played games, game duration and favourite game categories and experience, social media preference, language preference) and any other content you choose to provide as part of the survey response.

Missions: If you participate in any missions to be awarded with game credits (if available to you), we will require your email address to notify you of the redemption details (such as instruction on how to receive in-game credits).

Newsletters: If you choose to sign up for our mailing list to receive updates or newsletters on new games or upcoming launches, events and activities happening on GameLoop (if available in your region), we will send the updates or newsletters to your email.

2. Information about you generated as part of the App (and its in-App services)

We automatically collect certain data from you so that we can provide you with the many functions and services that comprise the App, namely:

Guid: If you choose to use the App via a guest log-in, the App will generate and assign you a globally unique identifier (guid) to set up your guest account and provide you access to the App.

Location data: To provide you the App: We use your IP address, location data (geographical location) and your language settings to determine your region to allow you to connect to the appropriate server, to facilitate your use of the App and to improve our services provided to you. To deliver advertisements to you: We also use your IP address and location data (geographical location) to deliver advertisements to you in the App.

User acquisition data via third parties (such as via Facebook Ads and Google Ads): If you click on a link or interact with content that advertises the App and you subsequently download and install the App, such data may be processed for analysis of advertisement and marketing analytics.

Advertising information via third-parties (such as via AppsFlyer and Adjust): Technical information and technical identifiers of your device or computer, and your engagement information may be processed to analyse and monitor the effectiveness of our advertisements and for the purposes of ad attribution.

Customer support and feedback information: We also receive certain information including your GameLoop App Log-in information, Open ID, IP address, device data, your email address, error log and the content of your feedback when you use the App’s support and feedback features for us to provide you with troubleshooting services to remedy technical issues and bugs, to administer customer support services to you and to improve our services to you.

Security-related information: When you are using the App, our security feature collects information about your device, network and system on which you are using this App (including basic hardware information, operating system information, machine codes for security authentication, user account information, network information, information of files, processes, modules, memory and driver which is related to the game running, user behaviour and status that may be related to plug-in use, image files, memory image and shellcode which is related to the game running, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots, external programs attempting to access private data which belongs to process of game application) for security purposes, including to detect cheating behaviours, provide a fair game environment in the App, and solve App crashes and improve our services.

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the App. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

For more information about our Cookies policy, click here.

Children

Children must not use the App for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions, we have listed the relevant minimum age in the table below:

Region in which the user is located	Minimum age of the user
Algeria	19
Bangladesh	18
Brazil	18
Canada	13
Egypt	18
European Economic Area/Switzerland	16
Hong Kong	18
India	18
Indonesia	21
Japan	20
Macau	18
Malaysia	18
Mexico	18
Philippines	18
Republic of Korea	14
Russia	14
Singapore	13
Sri Lanka	18
Taiwan	20
Thailand	20
Turkey	18
Vietnam	16

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at privacy@gameloop.com and we will delete such information.

Ho w We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”), Thailand, Brazil or Turkey (“Relevant Jurisdictions”), it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (only relevant if you are located in a Relevant Jurisdiction)
GameLoop App
Information you provide to us (either directly or through a third party)
GameLoop App Log-in information: information we import from your connected social media account if you choose to log-in via your social media account: Facebook: Name, Facebook ID, Profile Picture, Email Address (optional) Google: Google ID/Email Address, Display Name	We use this information to set-up and create your profile in accordance with your request, facilitate your log-in to the App, provide you access to the products and services on the App, maintain your account and provide customer service (where applicable).	Necessary to perform our contract with you to provide the App.
Game Log-in information: third party and social media (non-GameLoop) log-in account information for the relevant game, such as username, user ID, email address, profile picture(s) (if any), profile information and any such other information associated to these accounts (for example, Facebook, Google, Twitter, Apple Game Center, Nintendo, Pokemon Trainer Club, Garena, Activision, VK, where applicable) if you choose to access or log-in to games via the App.	To facilitate your log-in and access to games via the App.	Necessary to perform our contract with you to provide the App.
Survey Information: email, social media ID geographic (country) location, game information (game habits and preferences, e.g. recently played games, game duration and favourite game categories and experience, social media preference, language preference) and any other content you choose to provide as part of the survey response.	We use this information to better understand our users and to improve the App.	We only collect this information if you have provided your consent.
Missions: Email address, in-App activity	If you participate in any missions to be awarded with game credits (if available to you), we will require your email address to notify you of the redemption details (such as instruction on how to receive in-game credits).	Necessary to perform our contract with you to allow you to participate in missions.
Newsletters: Email address	If available in your region, if you choose to sign up for our mailing list to receive updates or newsletters on new games or upcoming launches, events and activities happening on GameLoop, we will send the updates or newsletters to your email.	We use this information only with your express consent.
Information generated as part of the App (and its in-App services)
IP Address, location data (geographical location), and your language settings.	We use this information to determine your region to allow you to connect to the server, to facilitate your use of the App and to improve our servers and services to you.	Necessary to perform our contract with you to provide this App.
	We use such information to deliver advertisements to you in the App, whether or not through third party providers.	It is in our legitimate interests to serve advertisements.
Guid assigned by the App	To facilitate your use of the App if you choose to use the App via a guest login	Necessary to perform our contract with you to provide this App.
User acquisition data via third-parties (such as via Facebook Ads and Google Ads) including advertising ID.	If you click on a link or interact with content that advertises the App and subsequently download the App, we may store such data for analysis of advertisement and marketing analytics.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Advertising information via third-parties (such as via AppsFlyer and Adjust): Technical information: technical information related to your device or computer, such as browser type, device type and model, system language, OS version. Technical Identifiers: various identifiers that generally identify your device, computer, or browser, for example, IP address, advertising ID, or other similar identifiers. Engagement information: your interactions with advertisements in the App, such as your clicks on ads, ad impressions viewed, audiences or segments to which an ad is attributed, website/application/game visited from the displayed advertisements, downloads and installations of applications and other interactions which we measure or analyse (whether through a third party or by ourselves).	We use this information for to analyse and monitor the effectiveness of our advertisements and for ad attribution purposes.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Support and troubleshooting: When you report an error, we collect your GameLoop App Log-in information, device data, Open ID, IP address, email address and the error log.	We use this information to provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the App.
Feedback: If you decide to use our feedback system, we collect your GameLoop App Log-in information, device data, Open ID, email address and the content of your feedback.	We collect this information to improve our services to you.	Necessary to perform our contract with you to provide this App.
Security-related information: basic hardware information, operating system information, machine codes for security authentication, user account information, network information, information of files, processes, modules, memory and driver which is related to the game running, user behaviour and status that may be related to plug-in use, image files, memory image and shellcode which is related to the game running, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots, external programs attempting to access private data which belongs to process of game application.	We use this information: for security purposes, including to detect cheating behaviours; to provide a fair game environment for users of the App; and to solve App crashes and to improve our services.	It is in our legitimate interests to use this information for security purposes.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your country). When this happens, we will provide more information on any specific changes to the way we process that personal information that might differ to this Privacy Policy prior to collecting or processing any additional information. In some cases, that information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with this App, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for this App are located in Germany, USA, India, and Singapore.

In addition, your information can be accessed from outside of where you are located by our support, engineering and other teams around the world.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

Companies within our corporate group who process your personal information in order to operate this App. All related group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the App or otherwise via the Internet; any transmission is at your own risk.

Data Re tention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
GameLoop App Log-in Information	Stored for the lifetime of your use of the App (i.e. until profile deletion in accordance with your request) and then for 30 days.
Guid	Stored for a year from collection, after which it will be deleted.
Location information: IP address, language settings (manually selected by you) location data (geographical location)	Stored for the lifetime of your use of the App (i.e. until profile deletion in accordance with your request) and then for 30 days.
Email address (for receiving or redemption of giveaway items such as in-game credits)	Stored for the lifetime of your use of the App (i.e. until profile deletion in accordance with your request) and then for 30 days.
Email address (for receiving newsletters and updates on new games launches and activities)	Stored for two years from collection, unless you choose to unsubscribe from the mailing list earlier.
Survey Information (where applicable)	Stored for a year from collection, after which it will be deleted.
User acquisition data via Facebook and Google	Stored for a year from collection, after which it will be deleted.
Advertising information via third parties (such as AppsFlyer and Adjust)	Stored for 180 days (i.e. until account deletion in accordance with your request, in which case this is deleted within 30 days).
Customer support and feedback information	Stored for a year from collection, or 30 days after the issue has been resolved, whichever is earlier.
Security-related information*	We generally retain this data for no longer than 90 days with the exceptions listed below. Upon a deletion request, we will delete the data within 30 days except where they relate to confirmed malicious activities. File sample collection and memory sample collection related to confirmed malicious activities: up to 10 years In-game process information and system information: up to 10 years. Security authentication: up to 5 years.

*Full description of data is set out in the section “How We Use Your Personal Information” above.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Your Rig hts

Some jurisdictions’ laws grant specific rights to users of the App, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, India and Russia.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at privacy@gameloop.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us at privacy@gameloop.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at privacy@gameloop.com.

Erasure

If there is any personal information you believe we process that you would like us to erase, please contact us at privacy@gameloop.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on this App and there are grounds for erasure, we will use reasonable steps to try to tell others who are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at privacy@gameloop.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at privacy@gameloop.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend App access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these App-related announcements, which are not promotional in nature.

Co ntact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@gameloop.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at privacy@gameloop.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you think we have infringed data protection laws.

Chan ges

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

SUPPLEMENTAL TERMS FOR USERS IN CERTAIN JURISDICTIONS

Some countries’ laws contain additional terms for users of this App, which are set out in this section. If you are a user located in a country listed below, then the terms set out below under the name of your country apply to you.

Algeria

By using this App you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (local cloud providers to back up your data or our affiliates around the world to help us deliver the App) located in Algeria (as described in the Privacy Policy) where it is manually and electronically treated.

Brazil

This section applies to users located in Brazil:

Language

This Privacy Policy is provided in Portuguese for users located in Brazil. In case of any inconsistency, the Portuguese version of this Privacy Policy shall prevail.

Consent Revocation

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact privacy@gameloop.com. This may affect our provision of the App to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the App for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Egypt

This Privacy Policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this Privacy Policy shall prevail.

By clicking “accept” or by proceeding with the sign-up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the App.

You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross-border transfer may be to any country in which we have databases or affiliates, in particular in Germany, USA, India, and Singapore.

Where applicable, you also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

Hong Kong SAR

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Age Restrictions

Parental consent is required for children under the age of 18 years to use the App.

Sensitive Personal Information

Sensitive Personal Information under local law includes passwords, financial information (such as bank account, credit card, debit card or other payment instrument details), biometric data, physical or mental health, sex life or sexual orientation, and/or medical records or history, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.

Sharing of Your Sensitive Personal Information

Where we permit any third parties to collect and use Sensitive Personal Information, we shall use reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information to the extent required by applicable laws.

Withdrawal of Consent

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at privacy@gameloop.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

Indonesia

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Data Subject Rights

You have the right to access your personal information stored in our App from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the App, we will notify you through the contact information provided by you or via the App, to the extent required by local laws and regulations.

Data Retention

We will retain your personal information in line with legal requirements.

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our App by unsubscribing or ceasing your use of the App at any time, if you cease to agree with the amended Privacy Policy.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

Minimum Age

If you are under the age of 20, you must obtain your parent’s or legal guardian’s consent to register an account on and use the App.

Consent to transfer to third parties

By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore, the United States, Hong Kong, and the PRC.

Your Rights

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at privacy@gameloop.com.

Macau SAR

You have the right not to provide your personal information. However, as a result, we may not be able to provide the App to you. As a Macau SAR data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Language

A version of this Privacy Policy in Bahasa Melayu is provided for users located in Malaysia. In the event of any discrepancy or inconsistency between the English version and Bahasa Melayu version of this Privacy Policy, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the App.

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the App, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Your Rights

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the App to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information
- Telephone: +603-22872388
- Email: privacy@gameloop.com

Mexico

Language

This Privacy Policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

Age Restrictions

You will not be able to use the App unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in section “The types of personal information we use” and section “How we use your personal information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

Some of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations or advertising. You may object the processing of your personal data for voluntary purposes as stated in the section “Your Rights” below.

Please be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section “How we store and share your personal information”.

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section “How we store and share your personal information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the App and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.

Your Rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data included in Section “Your Rights” above also apply to users that are located in Mexico.

You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer at privacy@gameloop.com.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer at privacy@gameloop.com.

Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in the relevant sections above). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the App may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookie policy.

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).

You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Contact

Data Protection Team, responsible for the management and safety of your personal information
Contact: privacy@gameloop.com

Philippines

Minimum Age

You must be at least 18 years of age to be able to use the App.

Your Rights

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

collecting and processing your personal information as described in the section “How We Use Your Personal Information” above;
sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
transferring or storing your personal information in destinations outside the Philippines as described in the section “How We Store and Share Your Personal Information” above.

South Korea

How We Store and Share Your Personal Information

Provision of personal information to third parties

We may provide your personal information to third parties as described below:

Name of Recipient (and contact information)	Types of Personal Information provided	Purpose of Use by Recipient	Period of Retention and Use by Recipient
AppsFlyer Ltd [link]	Advertising information	Analysis of advertising and marketing efficiency, ad attribution	In accordance with the AppsFlyer privacy policy
Adjust GmbH [link]	Advertising information	Analysis of advertising and marketing efficiency, ad attribution	In accordance with the Adjust privacy policy
Click Tech Limited [link]	Location data (geographical location), IP address.	Delivery of advertisements	For the duration of the user’s use of the App.
Mobvista International Technology Limited [link]	Location data (geographical location), IP address.	Delivery of advertisements	For the duration of the user’s use of the App.
TecDo Hong Kong Limited [link]	Location data (geographical location), IP address.	Delivery of advertisements	For the duration of the user’s use of the App.

Overseas Transfer of Personal Information

We may transfer personal information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)	Country/Territory to which Your Personal Information is to be Transferred	Date and Method of Transfer	Types of Your Personal Information to be Transferred	Purposes of Use by Recipients	Period of Retention of Use by Recipient
AppsFlyer Ltd	Ireland, Belgium	Transmitted from time to time	Advertising information	Analysis of advertising and marketing efficiency, ad attribution	180 days or upon request for deletion
Adjust GmbH	Germany, the Netherlands, and the US	Transmitted from time to time	Advertising information	Analysis of advertising and marketing efficiency, ad attribution	180 days or upon request for deletion
Click Tech Limited	Hong Kong SAR	Transmitted from time to time	Location data (geographical location), IP address.	Delivery of advertisements	For the duration of the user’s use of the App.
Mobvista International Technology Limited	Hong Kong SAR	Transmitted from time to time	Location data (geographical location), IP address.	Delivery of advertisements	For the duration of the user’s use of the App.
TecDo Hong Kong Limited	Hong Kong SAR	Transmitted from time to time	Location data (geographical location), IP address.	Delivery of advertisements	For the duration of the user’s use of the App.

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information detailed in section “Data Retention” are required to be retained pursuant to the following laws:

Act on the Consumer Protection in Electronic Commerce, Etc.

Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

Records regarding labelling and advertising (6 months)
Records regarding execution or withdrawal of a contract (5 years)
Records regarding the payment of a price and the supply of goods and services (5 years)
Records regarding customer services or dispute resolution (3 years)

Protection of Communications Secrets Act

Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act

Log records, IP address (3 months)
The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Your Rights

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the PIPA.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Specific considerations are as follows:

whether the additional use/provision is related to the initial purpose of the collection;
whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;
whether the additional use/provision unfairly infringe on the interests of the data subject; and
whether the necessary security measures such as pseudonymization or encryption were taken.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA, the information regarding the domestic agent is as follows:

Name: Tencent Korea Yuhan Hoesa
Address: 152 Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea

Telephone Number: +86 0755 8376 5566
Email: privacy@gameloop.com

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +86 0755 8376 5566
Email: privacy@gameloop.com

Russia

If you are using the App in Russia, this section “Russia” applies to you. By using the App, you consent to:

for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the App or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);
the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the People’s Republic of China (excluding Hong Kong, Taiwan and Macau);
for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy; and
for the purposes of Federal Law “On Marketing/Advertising”, that we may share advertising/marketing communications with you, unless you have opted-out from such communications.

The sub-sections “Access”, “Correction”, “Erasure”, “Restriction of Processing to Storage Only”, and “Objection” of the section “Your Rights” above apply to users in the Russian Federation.

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the App after the notification.

As regards the representative for Russia, you can contact us at privacy@gameloop.com. Please include the word “Russia” in the subject line of your email.

Sri Lanka

By clicking “accept”, you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Where you request to withdraw consent or, refrain from further processing of data or, erase or, rectify or, complete your personal information (where such personal information is inaccurate or incomplete), we will provide you with our response to the request within 21 working days.

Personalised Marketing

By clicking “accept”, you hereby consent to being shown personalised advertisements. You may choose to stop receiving personalised advertising from us by following the opt out instructions included in the Settings section of the App or by contacting us at privacy@gameloop.com.

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on the App. If you are under 7 years of age, please do not attempt to use or register for our App or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the App. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the App.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the App.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at privacy@gameloop.com.

We will give you notice by email of any material changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Vietnam

By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

We maintain international standards and security practices for data protection. When your personal information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

Your personal information, if required to be disclosed to the law enforcement agencies, public authorities or other judicial bodies and organisations, it will be disclosed upon receipt of written request from such organisations.

Your Rights

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.